https://www.taxtmi.com/caselaws?id=774048 The ITAT Chennai remanded a transfer pricing adjustment case to the TPO for fresh consideration. The assessee argued that AE relationship existed only for 2 months, not 12 months, and filed an addendum to Form 3CEB instead of revised forms. While noting procedural irregularities, the ITAT held these should not deny substantial justice. The tribunal found no business restructuring occurred as only share sale by director's foreign company ended AE relationship. The DRP initially rejected additional evidence on procedural grounds but later considered it on merits. ITAT directed TPO to allow revised Form 3CEB filing with additional evidence and decide afresh. en-us Mon, 09 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 17:03:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774048 The ITAT Chennai remanded a transfer pricing adjustment case to the TPO for fresh consideration. The assessee argued that AE relationship existed only for 2 months, not 12 months, and filed an addendum to Form 3CEB instead of revised forms. While noting procedural irregularities, the ITAT held these should not deny substantial justice. The tribunal found no business restructuring occurred as only share sale by director's foreign company ended AE relationship. The DRP initially rejected additional evidence on procedural grounds but later considered it on merits. ITAT directed TPO to allow revised Form 3CEB filing with additional evidence and decide afresh. Case-Laws Income Tax Mon, 09 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774048